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HERTFORDSHIRE BIOLOGICAL RECORDS CENTRE Environment, County Hall, Hertford, Herts, SG13 8DN

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HERTFORDSHIRE BIOLOGICAL RECORDS CENTRE Environment, County Hall, Hertford, Herts, SG13 8DN HERTFORDSHIRE BIOLOGICAL RECORDS CENTRE Environment, County Hall, Hertford, Herts, SG13 8DN Planning Policy Ask for: M. Hicks North Herts District Council Our Ref: District Council Offices Your Ref: Gernon Road Tel: 01992 556158 Letchworth Garden City SG6 3JF Date: 21/03/2013 Dear Sir Local Plan 2011 – 2031 Housing Options Growth Levels and Locations 2011 – 2031 Consultation Paper February 2013 I would like to make the following comments on the above consultation: 1. Housing Options Part 1: Housing Numbers 1. There is no indication as to how many of the strategic Sites might be used, or whether it may be that parts of all of them may be released for development, although if new discrete communities are planned with minimum sizes for facilities etc. this may not be an option. It is suggested that at least one will be required to meet the target of 10,700 dwellings (1.46). However, if somewhat variable, this could obviously have an impact on the environmental implications of any development. 2. Currently, the increase in proposed homes represents an increase of over 20% of the existing resource; this will also – crudely - increase the resulting generic environmental pressures such as increasing transport, water demand, pollution and disturbance by 20%, overall within the District and locally where development takes place. This may result in direct impacts such as the lowering of water tables if over-abstraction occurs, as well as increased nitrogen deposition, although it is hoped that measures will be taken in an attempt to address these issues as part of more detailed planning. 2. Housing Options Part 2: Strategic Sites 2.1 South West of Hitchin 2.1.1 It is noted that this proposal site lies directly adjacent to Oughtonhead Common (2.8) and will abut the AONB (2.8). Consequently it will have potential ecological and landscape implications, although this will be dealt with by others. Page 1 Sponsored by: HERTFORDSHIRE COUNTY COUNCIL, DACORUM BOROUGH COUNCIL, EAST HERTFORDSHIRE DISTRICT COUNCIL, HERTSMERE BOROUGH COUNCIL, CITY AND DISTRICT OF ST ALBANS, THREE RIVERS DISTRICT COUNCIL, WELWYN HATFIELD COUNCIL, NATURAL ENGLAND and ENVIRONMENT AGENCY 2.1.2 Oughtonhead Common is a Wildlife Site (WS), Local Nature Reserve and part HMWT reserve. It is important for wet marshy grassland and the river- head springs. This is a very important sensitive habitat which must be protected from adverse impacts, both direct and indirect. As such I would not wish to see any development west of Westmill, in the area that already forms an important buffer to the site. The existing development forms a good boundary to the settlement and further encroachment closer to the site will further increase the disturbance (which will be affected anyway) and management operations. Such an undeveloped area would be good Green Infrastructure (GI). The existing common is already present so cannot be ‘provided’ by any new development proposals, whilst the existing Oughtonhead Lane forms an acceptable boundary to the proposals, as already presented. If the area between Westmill and Oughtonhead must have some development it should NOT be for the whole width and should not be uniform but of a sinuous edge nature to enable ecological and landscape GI benefits to be provided. 2.1.3. Part of Oughtonhead Lane south of Westmill is an SSSI for its geological interest and must be properly protected with sufficient buffer areas to protect the special interest. 2.1.4. The Willows WS adjacent to Willow Lane, Hitchin, is within the proposals area and should be protected with appropriate buffers. 2.1.5. A buffer could be proposed for Charlton. Parts of the site along the River Hiz and Ippolyts Brook fall within the flood plains (2.12) and this includes Charlton Mill WS. The whole of the river valley and source of the Hiz is also important, and MUST be protected from development as part of any GI provision. This should also enhance the valley floodplains. Locally good farmland bird communities are known (Temple End) and this should be another consideration within the approach to GI. 2.1.6 The area also includes part of the existing and former Priory Park. Any proposal should conserve what survives and consider re-establishing the historic parkland where possible, given that some landscape features still survive. 2.1.7 Folly Alder Swamp WS is also within this area. Again, the importance of this, associated with the Ippolyts Brook, floodplain and river valley habitat cannot be overstressed and should be protected and enhanced within any development. 2.1.8 There are also currently some adjacent species wildlife sites, and the area supports a range of other protected species such as water vole, badger and bats. These are largely – but not exclusively - associated with the river valley complexes, and will also be supported by smaller scale features within the landscape. Priory Park icehouse is important for bats although this is not within the proposals area. Page 2 Sponsored by: HERTFORDSHIRE COUNTY COUNCIL, DACORUM BOROUGH COUNCIL, EAST HERTFORDSHIRE DISTRICT COUNCIL, HERTSMERE BOROUGH COUNCIL, CITY AND DISTRICT OF ST ALBANS, THREE RIVERS DISTRICT COUNCIL, WELWYN HATFIELD COUNCIL, NATURAL ENGLAND and ENVIRONMENT AGENCY 2.1.9 The general area used to support quite a number of orchards and it would therefore be appropriate to consider community orchard creation as part of any future GI provision. 2.1.10 On balance, given the provisions outlined above which I would consider are necessary to secure existing ecological interest and GI, I have no reason to believe there would be any fundamental ecological constraints associated with this proposal. There will be an impact on the existing farmland biodiversity although this is, of course, inevitable. Given the arable areas are intensively managed, the likelihood of significant harm is relatively low. However given the relative impact on known natural environment resources, the overall impact would be considered at moderate. If sufficient safeguarding provisions were not incorporated into any future development proposals, the potential could well be considered unacceptable. 2.2 North of Letchworth 2.2.1 This area does not support any statutory or non-statutory sites recognised for ecological importance. There are a number of local features that have been identified which border the site. Lizards and arable weeds have been recorded within the area and if still present, these would need to be taken into account in any detailed proposals. Great crested newts have also been recorded locally and may need to be similarly considered. Otherwise the area has been managed as intensive arable and is of limited ecological interest. Some remnant field patterns may support older hedgerow features. 2.2.2 On this basis, it would appear that there is little or no ecological constraint associated with this development proposal site. There is potential for GI depending upon the design layout, and this should include community orchard and allotment areas to ‘compensate’ in a small way for the loss of otherwise productive farmland. 3. East of Luton 2.3.1 This area contains no statutory or non-statutory ecological sites, although there are numerous large and small scale features that provide local ecological value that should be protected and incorporated as part of GI if the area was to be developed. A Wildlife Site is close by to the NE and a couple of historic orchards have been recorded from the area. No species of note are recorded on the HBRC database although this is most certainly a function of a lack of recording effort in this area, which will certainly support foraging bats. Other than woodland the land use is intensive arable, although there is a network of what are probably historic and remnant hedgerows. Page 3 Sponsored by: HERTFORDSHIRE COUNTY COUNCIL, DACORUM BOROUGH COUNCIL, EAST HERTFORDSHIRE DISTRICT COUNCIL, HERTSMERE BOROUGH COUNCIL, CITY AND DISTRICT OF ST ALBANS, THREE RIVERS DISTRICT COUNCIL, WELWYN HATFIELD COUNCIL, NATURAL ENGLAND and ENVIRONMENT AGENCY 2.3.2 On the basis of this evidence, there would appear to be little if any ecological constraints to development, although the character of the countryside locally and the existing settlement pattern would be considerably affected. However major ecological features would be expected to be incorporated into any development as GI, and provision of allotments and a community orchard to reflect the loss of otherwise productive farmland. Ecologically this proposal is likely to have limited ecological constraints. 2.4. Rush Green 2.4.1 The proposal site is limited entirely to the highly disturbed scrap metal site of Rush Green. Rush Green Airfield Wildlife Site is almost directly adjacent to the north-west, but is unlikely to be directly affected. The area is within the range of local great crested newts and these may be present within the site given the remnant vegetation resources and potential cover, although little other semi-natural habitat is present. No other protected species interest is known to be present from the database. The site supports a scattering of mature trees and some could be retained in any development proposals. 2.4.2 This site has no recognised ecological interest and is unlikely to support biodiversity of any significance, although locally trees and GCN may be present. It therefore has no known ecological constraints and is of very low sensitivity. Potential GI could incorporate existing trees and develop community orchards to reflect the former farm within a sensitive development, although whether this could provide a new independent settlement or overcome other issues needs to be considered. 2.5. North of Stevenage 2.5.1 The whole site is managed as intensive arable with small areas of recent planting and grassland (for game?) with remnant hedgerows / boundary features.
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